Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for second-degree murder, holding that the court of appeals erred in concluding that the trial court erred by denying Defendant's motion to suppress evidence generated from his blood but that the error was not prejudicial.In denying Defendant's suppression motion the court of appeals held that the trial court erred by not excluding Defendant's blood test results but that Defendant failed to carry his burden to show that the denial of his motion to suppress resulted in prejudicial error. The Supreme Court reversed, holding that the court of appeals applied the incorrect standard for determining prejudice resulting from the violation of Defendant's rights under the United States Constitution. View "State v. Scott" on Justia Law

The Supreme Court reversed the decision of the court of appeals finding no error in the judgments of conviction in this case, holding that the court of appeals erred in concluding that Defendants' claims had not been properly preserved for appeal.Three defendants were tried together as co-defendants for the involvement in a crime where armed robbers stole nearly half a million dollars from Raleigh's Walnut Creek Amphitheater. Following their convictions two defendants appealed, arguing that the trial court erred in denying their motions for separate trials. The court of appeals affirmed the convictions, concluding that because the grounds for severance argued that the beginning of trial were different from the grounds relied upon by Defendants on appeal, Defendants' claims had not been properly preserved for appeal. The Supreme Court reversed, holding that the court of appeals erred in analyzing the case as one involving severance of offenses rather than severance of defendants. View "State v. Melvin" on Justia Law

The Supreme Court reversed the judgment of the court of appeals remanding judgments entered by the superior court for a hearing to determine Defendant's competency at the time of trial, holding that the trial court did not err by failing to hold a second competency hearing immediately prior to the beginning of Defendant's trial on its own motion.Defendant was charged with selling and delivering buprenorphine, maintaining a vehicle for the purpose of selling buprenorphine, possession of buprenorphine with the intent to sell or deliver, and having attained habitual felon status. Defendant was convicted. On appeal, Defendant argued that the trial court had erred by failing to hold a second competency hearing before the beginning of his trial. The court of appeals agreed and reversed. The Supreme Court reversed, holding that Defendant was not entitled to relief on his challenge to the trial court's failure to inquire into his competence to stand trial on its own motion. View "State v. Allen" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the trial court ordering Defendant to register as a sex offender under N.C. Gen. Stat. 14-202(l), holding that the evidentiary facts supported the trial court's ultimate fact that Defendant was a danger to the community.Defendant pled guilty to secret peeping pursuant to N.C. Gen. Stat. 14-202(d). The trial court placed Defendant on supervised probation and ordered him to register as a sex offender. The court of appeals affirmed the trial court's order requiring Defendant to rester as a sex offender, concluding that the trial court's finding that Defendant was a "danger to the community" was supported by competent evidence. The Supreme Court affirmed, holding that the court of appeals did not err in affirming the trial court's order requiring Defendant to register as a sex offender based on the finding that he was a danger to the community. View "State v. Fuller" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating Defendants' convictions of second-degree murder and ordering a new trial, holding that the trial court committed prejudicial error in excluding evidence that was highly relevant as to Defendants' self-defense claims.Defendants, Thomas Martens and his daughter, Molly Corbett, were found guilty of murdering Molly's husband, Jason Corbett. During trial, Defendants maintained that they had lawfully used deadly force to defend themselves while under a reasonable apprehension that they were facing an imminent threat of deadly harm during an interaction initiated by Jason. The Supreme Court remanded the case to the trial court for a new trial, holding that the trial court erroneously excluded certain evidence, thus depriving Defendants of their ability to present a full and meaningful defense. View "State v. Corbett" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for felonious obstruction of justice, holding that the record contained sufficient evidence that Defendant acted with deceit and intent to defraud to support her conviction.Defendant's daughter had been sexually abused by Defendant's husband. Defendant's conviction arose from her actions in interfering with the ability of social workers and law enforcement officers to have access to her daughter. Defendant appealed, arguing that the evidence was insufficient to support her conviction. The court of appeals upheld the conviction. The Supreme Court affirmed, holding that the record evidence provided sufficient support for a jury to find that Defendant precluded investigating officials from accessing her daughter with deceit and the intent to defraud. View "State v. Ditenhafer" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction, holding that the trial court erred by failing to conduct a competency hearing under the circumstances of this case.After a jury trial, Defendant was found guilty of felony embezzlement. At issue on appeal was whether the trial court erred in declining to hold a competency hearing when Defendant attempted suicide one evening after her trial had recessed for the day and was thereafter involuntarily committed. The trial court concluded that Defendant had voluntarily waived her constitutional right to be present at her trial because of her suicide attempt and therefore proceeded with the trial without Defendant. On appeal, Defendant argued that the trial court was required to conduct a competency hearing before proceeding with the trial in her absence. The court of appeals affirmed. The Supreme Court reversed and remanded the case for a new trial, holding that the trial court was presented with substantial information that cast doubt on Defendant's competency, and the trial court erred by failing to hold a competency hearing. View "State v. Sides" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing Defendant's conviction, holding that the court of appeals correctly held that the trial court committed plain error when it admitted improper testimony by an investigator with the Department of Social Services (DSS) Child Protective Services who improperly vouched for the victim's testimony.Defendant was convicted of sexual offense with a child by an adult, child abuse by a sexual act, and indecent liberties with a child. On appeal, Defendant argued that the trial court erred in allowing the DSS investigator's testimony. The court of appeals concluded that the trial court committed plain error requiring a new trial because the DSS investigator's testimony improperly bolstered or vouched for the victim's credibility. The Supreme Court affirmed, holding that the trial court commits a fundamental error when it allows testimony which vouches for the complainant's credibility in a case where the verdict entirely depends upon the jurors' comparative assessment of the complainant's and the defendant's credibility. View "State v. Warden" on Justia Law

The Supreme Court reversed the trial court's denial of Defendant's motion for appropriately relief filed after he was convicted of two counts of first-degree murder, holding that certain undisclosed evidence was material and that it was reasonably probable that, had it been disclosed to Defendant prior to trial, the outcome would have been different.Defendant was convicted of first-degree burglary, first-degree rape, robbery with a dangerous weapon, and two counts of first-degree murder and sentenced to death. The convictions were affirmed on direct appeal. In postconviction proceedings, it became clear that the State failed to produce certain pieces of evidence to Defendant prior to his trial. Later that year, postconviction counsel uncovered additional evidence. Defendant then filed a motion for appropriate relief, arguing that the State failed to disclose exculpatory evidence in violation of his due process right pursuant to Brady v. Maryland, 373 U.S. 83 (1963). The trial court denied the motion. The Supreme Court reversed and remanded this case with instruction to grant the motion and order a new trial, holding that the failure to disclose the exculpatory evidence prejudiced Defendant's ability to present a defense. View "State v. Best" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's convictions, holding that the trial court abused its discretion when it "flatly prohibited questioning as to issues of race and implicit bias during voir dire" and that the trial court's improper restrictions on Defendant's questioning during voir dire prejudiced Defendant.Defendant was convicted of several crimes, including robbery with a dangerous weapon and second-degree kidnapping. On appeal, Defendant challenged the trial court's refusal to allow him to pursue during voir dire certain lines of inquiry relating to racial bias and police-officer shootings of black civilians. The court of appeals rejected Defendant's claims and found no error in the trial court's judgment. The Supreme Court reversed, holding that the trial court abused its discretion and prejudiced Defendant by restricting all inquiry into prospective jurors' racial biases and opinions regarding police officer shootings of black men. View "State v. Crump" on Justia Law